DOD GUIDEBOOK FOR CONTRACT PROPERTY ADMINISTRATION

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DOD GUIDEBOOK FOR CONTRACT PROPERTYADMINISTRATIONDraft Dated 7/28/11

ForewordThe Government relies on and requires its contractors to provide effective andefficient stewardship of the Government property in their custody. This stewardship responsibility, codified in the Federal Acquisition Regulation (FAR) clauses52.245-1, Government Property, and 52.245-2, Government Property InstallationOperation Services, is the subject of this Guidebook.The policies and procedures presented in this Guidebook are designed to implement the requirements of the FAR, facilitate the effective and efficient oversightof contractors, maximize the Department’s return on investment and achievementof best value; and protect the Government’s interests. The terms and condition ofthe contract take precedence over the requirements of this Guidebook.This Guidebook replaces DoD 4161.2-M, DoD Manual for the Performance ofContract Property Administration (1991). To ensure ease of updates and accessibility, this guide is being made available in printable electronic format.iii7/28/11

ContentsChapter 1 Government Property Stakeholders . 1-1STAKEHOLDER ROLES . 1-1PA RESPONSIBILITIES . 1-2ETHICS OF CONTRACT PROPERTY ADMINISTRATION . 1-3Chapter 2 Acquisition . 2-1PA RESPONSIBILITIES . 2-1Chapter 3 Receiving . 3-1PA RESPONSIBILITIES . 3-1Chapter 4 Support Property Administration . 4-1REQUESTING SPA FOR SUBCONTRACTOR SITES . 4-1REQUESTING SPA FOR ALTERNATE SITES . 4-2PRIME PA RESPONSIBILITIES . 4-2SUPPORTING PA RESPONSIBILITIES . 4-4Chapter 5 Records . 5-1PA RESPONSIBILITIES . 5-1Chapter 6 Maintenance. 6-1PA RESPONSIBILITIES . 6-1PREVENTIVE MAINTENANCE . 6-1CORRECTIVE MAINTENANCE . 6-2CAPITAL-TYPE REHABILITATION . 6-3Chapter 7 Subcontract Control. 7-1PA RESPONSIBILITIES . 7-1Chapter 8 Utilization . 8-1PA RESPONSIBILITIES . 8-1Chapter 9 Storage . 9-1PA RESPONSIBILITIES . 9-1BONDED STORAGE . 9-1COMMINGLING . 9-2iv7/28/11

Chapter 10 Consumption . 10-1CONSUMPTION DRIVERS . 10-1CONSUMPTION PROCESS . 10-1UNREASONABLE CONSUMPTION . 10-3Chapter 11 Physical Inventory . 11-1PA RESPONSIBILITIES . 11-1Chapter 12 Disposition/Contract Close-Out . 12-1PA RESPONSIBILITIES . 12-1Chapter 13 Reports . 13-1REPORTS ON PROPERTY LOSS . 13-1REPORTS OF INVENTORY, AUDIT, AND REVIEW RESULTS . 13-2Chapter 14 Contractor Self-Assessments . 14-1BACKGROUND . 14-1PROCESS . 14-1OBJECTIVITY . 14-2AUDIT PROGRAM AND WRITTEN PROCEDURES. 14-3PA VALIDATION OF CONTRACTOR SELF-ASSESSMENT. 14-3USING CONTRACTOR SELF-ASSESSMENT RESULTS IN ASSESSING RISK ANDPERFORMING PMSAS . 14-4INTERNAL AUDIT AND ASSESSMENT RECORDS . 14-5Appendix A Statistical Sampling TablesAppendix B Guidance on Significant/Systemic FindingsAppendix C Guidance on Scrap ProcessingAppendix D Guidance on Arms, Ammunition, and ExplosivesAppendix E ResourcesAppendix F Abbreviationsv7/28/11

Chapter 1Government Property StakeholdersThis guidebook sets forth policy and guidance for Government property stakeholders: Program Managers (PMs), Contracting Officers (COs), Contract Specialists (CSs), and Accountable Property Officers, along with those designated theresponsibility of oversight of stewardship, including Property Administrators(PAs) and Plant Clearance Officers (PLCOs).STAKEHOLDER ROLESThe Government property stakeholder roles can be summarized as follows: The PM is the designated individual with the responsibility to accomplishprogram objectives for development, production, and sustainment to meetthe user's operational needs. The CO is responsible for ensuring contractor compliance with the termsand conditions of the contract, to include contract property management.Note: In the absence of an assigned PA, the CO is also responsible for thePA roles described below, in accordance with agency procedures. The PA is an authorized representative of the CO, appointed in writing bya Certificate of Appointment (and in accordance with agency procedures)to administer the contractual and technical aspects of the Governmentproperty provisions, terms, and conditions of Government contracts. Direction for the appointment of PAs is provided in Defense Federal Acquisition Regulation Supplement (DFARS) 245.7001. The PLCO is an authorized representative of the CO, appointed in writingby a Certificate of Appointment (and in accordance with agency procedures) to administer the clearance of excess Government property from thecontractor’s stewardship account. Direction for the appointment of PLCOsand a list of PLCO responsibilities are provided in Defense Federal Acquisition Regulation Supplement (DFARS) 245.7001 and 245.7002. The Defense Contract Audit Agency (DCAA) is responsible for determining whether contractor costs are reasonable, allowable, or allocable.1-17/28/11

PA RESPONSIBILITIESPA responsibilities for each aspect of Government property administration areaddressed in the related chapters of this Guidebook. The PA’s overall responsibilities require the PA to do the following: Plan, develop, and perform a property management system analysis andaudits in accordance with GAO-03-673G, Government Auditing Standards(“The Yellow Book”). Audit planning includes conducting a risk analysisby process; establishing audit objectives with stakeholders; determininglots, confidence levels, and data collection methods; scheduling audit visits; and coordinating support. Research, evaluate, and determine the adequacy of the contractor’s property management system, including internal audit processes, procedures, andresults in accordance with FAR 9.104-1(e). Make recommendations for corrective action and continuous improvementin accordance with FAR 1.102-4(e) and FAR 52.245-1(g)(3). Conduct the necessary system analysis or audit to ensure contractor performance and compliance with contract property terms and conditions.The PA determines the schedule and extent of analysis required. This determination must be based on the contractor system’s complexity, contractor self-assessment methods, and/or other factors—such as risk to theGovernment—as identified by the PA. A system analysis must be accomplished as frequently as conditions warrant. Review contracts to recognize the objectives that justify the provision ofGovernment property, and plan surveillance to achieve those objectives inan auditable, efficient manner. For example, use supporting delegationsand/or assistance from technical specialists, verify the inclusion of appropriate clauses, ensure Government property is appropriately identified, andconfirm that general and special contract provisions are included in thecontract. Ensure the contract file identifies stakeholders, includes contract deficiency reports, recognizes the objectives of the business case presented by thePM to comply with the 245 acquisition objectives in the DoD Procedures,Guidance, and Information (PGI), and identifies risks associated with theproperty list and terms. Evaluate contractor performance with contractual requirements, to includethe use of voluntary consensus standards and/or industry leading practices;and ensure consistency with the property life-cycle process outcomes specified in FAR 52.245-1.1-27/28/11

Notify contractor managerial personnel when the contractor’s propertycontrol system presents an undue risk to the Government; and monitor thecorrection of the contractor’s property control system. Assist COs, PMs, logisticians, auditors (such as DCAA), and other Government personnel; and advise the CO and/or other Government personnelregarding the contractor's failure to perform in accordance with contractual requirements. Notify the CO and other appropriate Government personnel in the event ofexcessive or improper acquisition by the contractor, and recommend appropriate remedies. Participate in preaward and post-award surveys to advise on the status ofthe contractor’s property management system and capabilities, and to advise the contractor of its contractual obligations pertaining to the management of Government property. Investigate occurrences of property losses to advise the CO of liability orto relieve the contractor of responsibility. Ensure appropriate actions aretaken to manage the risk of future loss. Review contractor-generated reports, such as physical inventory resultsand reports of loss, damage, destruction, and theft. Perform other property-related responsibilities as prescribed by the FAR,DFARS, Agency regulations and supplements, certificates of appointment,support property delegations, and this Guidebook. Conduct agency, program, and other customer-requested reviews involving contract property. Oversee contractual disposal actions and processing requests for disposaldirections.ETHICS OF CONTRACT PROPERTY ADMINISTRATIONContract property administration requires that the highest degree of ethical standards be applied by both Government and contractor personnel. Questionable andunethical property practices must be immediately reported by Government personnel through appropriate management levels in accordance with agency regulations.1-37/28/11

Chapter 2AcquisitionContractors acquire property through various means, including purchase, transfer,and fabrication. A contract might call for new property to be purchased by thecontractor for use under the contract. The Government might transfer its ownproperty to the contractor for use under the contract. Or, the contract might callfor the contractor to produce—or fabricate—property for the Government. Thecontractor’s acquisition of property is regulated by FAR 52.245-1, GovernmentProperty; the applicable Cost Accounting Standards; and FAR 52.216-7, Allowable Cost and Payment.Most contractors acquire property through an established purchasing system. Material control organizations initiate purchase requisitions (PRs), which are thensubmitted to the contractor’s purchasing function. Source documents includeMilitary Standard Requisitioning and Issue Procedures (MILSTRIP) requisitions,purchase orders, transfer documents, petty cash documents, and fabrication orders. Supporting documents include purchase requisitions and engineering changeproposals (ECPs). It is the PA’s responsibility to ensure this basic process complies with the related acquisition regulations.PA RESPONSIBILITIESThe PA must examine requisition and fabrication procedures, and perform sufficient testing to ensure that the contractor: Has contractual authority for the acquisition of property, including property obtained from Government supply sources. Properly prepares and processes MILSTRIP requisitions, including routingidentifiers and priority designators. Provides for internal reviews of available in-house items that are remaining from other (contractual) requirements. Has the necessary internal controls to ensure purchased quantities are reasonable (consistent with the contract type and scope). Performs actions in a timely manner. Maintains adequate support and supporting documentation. This includesproperly maintained files that reflect the status of requisitions and otheracquisition documents.2-17/28/11

Demonstrates appropriate follow-up actions. Ensures that (when the purchase order is for property for more than onecontract), the quantity acquired for each contract is specified in the purchase order or supporting documentation, for proper charging.2-27/28/11

Chapter 3ReceivingReceiving involves the process of physically receiving incoming property. It is atthe point of receipt when the contractor becomes accountable and responsible forGovernment property. The contractor also must define an auditable method todocument the process of verification and posting of receipts in compliance withASTM E2605-08, Standard Practice for Receiving Property; or other voluntaryconsensus standard. Source documents include receiving reports; and supportingdocuments include Government bills of lading and packing lists.PA RESPONSIBILITIESIt is the PA’s responsibility to examine the contractor’s receiving controls andprocedures and perform sufficient testing to ensure that the contractor: Promptly notifies the PA when overages, shortages, damages, or other discrepancies are discovered upon receipt of Government-furnished property. Obtains the carrier’s signature when shortages or other discrepancies areidentified at the time of delivery. Takes actions necessary to make required adjustments for overages, shortages, damages, and other discrepancies upon receipt of contractoracquired property. Reconciles property received with documentation, such as purchase ordersand packing lists. Promptly distributes receiving reports to designated control points andrecords the Government property in the property management records. Adequately protects and stores property during the receiving process. Properly segregates, stores, and accounts for reusable containers in theproperty management system. Ensures the proper recording of quantity received, condition, date received, and other information necessary to meet the record reporting requirements of FAR 52.245-1. Updates the DoD Item Unique Identification Registry as required byDFARS 252.211-7007, Reporting of Government-Furnished Equipment inthe DoD Item Unique Identification (IUID) Registry, as applicable.3-17/28/11

Chapter 4Support Property AdministrationThe contractor is responsible and accountable for all Government property, includingproperty in the possession of its subcontractors and property at its alternate locations.Included with this responsibility is a contractual obligation to periodically review theadequacy of the subcontractor’s property management system. In addition, whenproperty is located at a contractor’s alternate site, the contractor’s self-assessmentprogram should include periodic reviews and audits necessary to assess the effectiveness of the site’s property management system.The prime PA is responsible for determining the necessity, type, and scope of support property administration (SPA). The sections below provide guidance to property personnel on requesting and accepting SPA for both subcontractor sites andalternate sites of the prime contractor.REQUESTING SPA FOR SUBCONTRACTOR SITESNormally the prime PA will not request SPA at a subcontractor’s premesis, unless The Government otherwise would incur undue cost; Successful completion of the prime contract is threatened; or The SPA is authorized under FAR 42.202 (f), Assignment of ContractAdministration—Special Surveillance.If the prime contractor is found to have inadequate subcontractor control, the PAmust consider whether the value and criticality of the property at the subcontractor’s locations increase the Government’s risk of incurring undue cost or threatenthe successful completion of the prime contract sufficiently to justify obtainingassistance from a supporting PA. If SPA is requested because the prime contractorhas inadequate subcontractor control, the SPA delegation should be of limited duration, to be terminated when the prime PA’s subcontractor control process is corrected.The prime contractor is contractually obligated to manage its subcontracts. Accordingly, SPA will not be requested except in the circumstances identifiedabove. In no event will SPA be delegated solely on the basis of a contractor’s request.4-17/28/11

REQUESTING SPA FOR ALTERNATE SITESThe prime PA may request SPA at the contractor’s alternate site if, in the PA’sjudgment, the prime contractor’s periodic internal reviews and audits of that facility are not adequate to protect the Government’s interest. Among the factors to beconsidered with regard to SPA is whether DoD is already performing propertyadministration at the contractor’s alternate site. If so, accepting SPA may not significantly increase the supporting PA’s workload.PRIME PA RESPONSIBILITIESThe prime PA has the responsibility for determining whether and when SPA willbe in the Government’s best interests.When the prime PA determines that SPA for a subcontractor is appropriate, thePA must also determine whether the prime contractor will accept the findings ofan SPA. This is necessary because the Government does not have a contractualrelationship with the subcontractor; rather, the prime contractor has that contractual relationship—known as privity of contract—with the subcontra

the contract take precedence over the requirements of this Guidebook. This Guidebook replaces DoD 4161.2-M, DoD Manual for the Performance of Contract Property Administration (1991). To ensure ease of updates and accessi-bility, this guide is being made available in printable electronic format.

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